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05000397/FIN-2018003-03Failure to Adequately Control Work Hours for Covered Personnel2018Q3The inspectors identified a Green, non-cited violation of 10 CFR 26.205 associated with the licensees failure to adequately schedule and control work hours for personnel subject to work hour controls. Specifically, the licensee failed to appropriately schedule and control work hours for at least three Chemistry Technicians who were providing covered work as the designated Emergency Response Organization (ERO) Duty Chemistry Technician as defined by the Columbia Generating Station Emergency Plan.
05000397/FIN-2018003-02Failure to Control Workers in a High Radiation Area (>1.0 rem per hour)2018Q3The inspectors reviewed a self-revealed Green, non-cited violation of Technical Specification (TS) 5.7.2(b) and (e) when the licensee failed to control worker activities in a locked high radiation area in accordance with the requirements of the RWP and failed to determine radiological conditions in the work area prior to the start of work.
05000397/FIN-2018003-01Failure to Follow Radiologically Controlled Area Procedures2018Q3The inspectors reviewed a self-revealed Green, non-cited violation of Technical Specification 5.4.1(a) when the licensee failed to implement radiation control procedures. On June 1, 2017, a supplemental health physics technician (HPT) entered a posted locked high radiation area without a functioning electronic dosimeter (ED). Although the area was posted as a locked high radiation area (LHRA), there were no measured dose rates in excess of 1 rem per hour during this entry. The HPT logged on to Radiation Work Permit (RWP) 30003852 and entered the radiologically controlled area (RCA) to cover a job to add additional shielding in the travelling in-core probe (TIP) Mezzanine room. The HPT entered the RCA through the HP swing gate near the RCA exit point, in order to obtain survey instruments for the job coverage. The HPT proceeded to the dress out area and then to the TIP Mezzanine room, where he entered with a survey meter. After about 10 minutes in the room, the HPT looked at his ED and noticed that it was in pause mode (i.e., not functioning). The HPT informed the worker he was covering, and they both left the LHRA. During the RWP logging process, there was an error when the HPTs ED was being programmed that went unnoticed. As a result, the HPT was signed-on to the RWP, but the ED was not programmed and active. Because the HPT used the HP swing gate at the RCA exit rather than the normal access point with electronic turnstiles that verify ED function, this errant condition was not identified. The swing gate used was intended for HPTs assigned to assist workers with contamination alarms at the RCA exit, not as an RCA entry point to perform work or cover a job. Licensee Procedure GEN-RPP-04, Entry Into, Conduct In, and Exit From Radiologically Controlled Areas, Section 4.13 Dosimetry and Log-in, paragraph (e), requires workers to ensure that electronic dosimetry is on immediately before entering the RCA. The HPT neither used the electronic turnstiles nor checked to see if the ED was on prior to entering the RCA.Additionally, licensee Procedure 11.2.7.3 High Radiation Area, Locked High Radiation Area, and Very High Radiation Area Controls, Section 3.2.4 Coverage and Monitoring of Work, paragraph (d), describes conducting a peer-check prior to LHRA entries, by the job coverage HPT, to verify that workers are wearing an active ED (i.e., not in pause mode) in the appropriate location on the body. The job coverage HPT checked to see that workers had an ED appropriately placed, but did not check the ED setpoints or if the ED was active.Multiple barriers that could have prevented this situation from occurring were either ineffective or not used. Had the error reduction/prevention measures been used, the ED programming error during RWP log on would have been identified.Corrective Action(s): An immediate corrective action, in addition to the HPT being restricted from the RCA, was a stand down conducted with radiation protection personnel about this incident and coaching on use of the procedures related to the verification of dosimetry and peer-checking prior to entry into LHRAs. Corrective Action Reference: AR 00366701
05000397/FIN-2018003-04Licensee-Identified Violation2018Q3This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy. Title 10 CFR 20.1902(a) requires the licensee to post each radiation area with a conspicuous sign bearing the radiation symbol and the words "CAUTION, RADIATION AREA."Contrary to the above, from November 9, 2017 to November 13, 2017, the licensee failed to post a radiation area with a conspicuous sign bearing the radiation symbol and the words "CAUTION, RADIATION AREA."The licensee moved two resin liners with high dose rates into the turbine building truck bay. Once the resin liners were in the turbine building truck bay, a high radiation area boundary was posted around them. However, the dose rates outside the truck bay doors were not verified. On November 13, 2017, the licensee, while conducting routine area surveys, identified an unposted radiation area outside the turbine building truck bay doors, which resulted from the resin liners inside of the truck bay area. The licensee secured the radiation area and adequately posted it, as required.
05000397/FIN-2018002-01Failure to Maintain Configuration Control in the Diesel Generator 2 Diesel Cooling Water System2018Q2The inspectors reviewed a self-revealed, Green, non-cited violation of Technical Specification 5.4.1.a for the licensees failure to perform maintenance in accordance with written procedures appropriate to the circumstances. Specifically, on April 9, 2018, the licensee inadvertently bumped and partially opened a diesel cooling water valve, DCW-V-8B2, while operating a nearby demineralized water valve, DW-V-14B2, as part of work activities under Work Request (WR) 29127677, and rendered diesel generator 2 inoperable and unavailable.
05000397/FIN-2018401-02Security2018Q1
05000397/FIN-2018401-01Security2018Q1
05000397/FIN-2018001-01Failure to Follow Procedure Leads to Loss of Secondary Containment2018Q1The inspectors reviewed a self-revealed, Green, non-cited violation of Technical Specification 5.4.1.a for the licensees failure to perform maintenance in accordance with documented instructions appropriate to the circumstances. Specifically, on September 12, 2017, the failure to verify power sources per Work Order 02072924 caused an electrical transient that caused the reactor building exhaust valve and supply valve to lose power and close, resulting in a loss of secondary containment
05000397/FIN-2017010-02Failure to Control a High Radiation Area with Dose Rates Greater Than 1000 Millirem Per Hour at 30 Centimeters2017Q3The inspectors identified a non-cited violation of Technical Specification 5.7.2 for the failure to control a high radiation area with dose rates greater than 1000 millirem per hour at 30 centimeters. Specifically, equipment boxes placed adjacent to high radiation area barrier fencing in the reactor building 471 elevation, which created a natural ladder into the area, resulted in an uncontrolled entryway to a high radiation area with dose rates greater than 2500 millirem per hour. Once informed, the licensee immediately removed the equipment boxes from the barrier and added signage that restricted the placement of any items adjacent to the fencing forming the high radiation area barrier. This issue was documented in the licensees corrective action program as Action Request AR 00355646. The failure to properly control and barricade an entryway to a locked high radiation area in the reactor building, 471' elevation, was a performance deficiency. The performance deficiency was more than minor because it was associated with the program and process (exposure control) attribute of the Occupational Radiation Safety Cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material. Using NRC Inspection Manual Chapter 0609, Appendix C, "Occupational Radiation Safety Significance Determination Process, the inspectors determined that the finding had very low safety significance (Green) because the finding was not an as low as reasonably achievable planning or work control issue, there was no overexposure or potential for an overexposure, and the licensee's ability to assess dose was not compromised. The finding had a cross- cutting aspect in the area of Human Performance, Field Presence, because leaders were not commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations, resulting in a lack of oversight of work activities, to include contractors and supplemental personnel (H.2).
05000397/FIN-2017003-01Inadequate High Pressure Core Spray Fill and Vent Procedure2017Q3The inspectors reviewed a self -revealed, non- cited violation of Technical Specification 5.4.1.a, for the licensees failure to have a high pressure core spray system fill and vent procedure appropriate to the circumstances. The licensee entered this issue into the corrective action program as Action Request 368872. The failure to have a high pressure core spray system fill and vent procedure appropriate to the circumstances was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it affected the equipment performance at tribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Procedure SOP- HPCS -FILL, HPCS Fill and Vent, Revision 11, was not appropriate to the circumstances in that it did not ensure the high pressure core spray instrumentation lines were clear of voids. As a result, air remained in the instrumentation lines , and the high pressure core spray minimum flow instrument, HPCS -FIS -6, was degraded. The inspector s performed the initial significance determination using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that the finding was of very low safety significance (Green) because: (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding did not represent an actual loss of function of one or more non- technical specification trains of equipment designated as high safety -significant in accordance with the licensees maintenance rule program for greater than 24 hours. This finding had a cross -cutting aspect in the area of human performance, avoid complacency, in that the licensee failed to recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes (H.12).
05000397/FIN-2017003-02Failure to Report Unplanned Valid Reactor Protection System Actuation2017Q3The inspectors identified a Severity Level IV, non- cited violation of 10 CFR 50.72(b)(3)(iv)(A) for the licensees failure to submit an event notification to the NRC 3 within 8 hours of occurrence of an unplanned valid reactor protection system actuation of the reactor protection system. Specifically, the licensee did not report are actor protection system Level 3 scram actuation when reactor vessel level dropped below +13 inches until prompted by the inspectors. The licensee subsequently restored compliance and reported the event in accordance with 10 CFR 50.72(b)(3)(iv)(A) on August 24, 2017, as an update to Emergency Notification System Report 52918 and entered the issue into their corrective action program as Action Request 370529 . The licensees failure to submit the event notification was a violation that impacted the regulator y process and warrants treatment using traditional enforcement . In accordance with Section 2.2.4 and the example in Section 6.9.d.9 of the NRC Enforcement Policy, dated November 1, 2016, the violation was determined to be a Severity Level IV violation. Traditional enforcement violations are not assessed for cross- cutting aspects.
05000397/FIN-2017010-01Failure to Transfer Byproduct Material to a Disposal Facility in Accordance with the Terms of the Facilitys License2017Q3The inspectors reviewed a self-revealed non-cited violation of 10 CFR 30.41(b)(5) for the failure to transfer byproduct material to an authorized waste disposal facility in accordance with the terms of the facilitys license. Specifically, License Condition No. 21.C of the US Ecology license requires that all radwaste shall be packaged in such a manner that waste containers received at the facility do not show an increase in the external radiation levels as recorded on the manifest, within instrument tolerances. On July 20, 2017, Columbia Generating Station personnel transferred byproduct material to US Ecology for disposal (Shipment 17-51). The disposal facilitys surveys identified that the dose rate on contact with the waste liner was 1100 millirem per hour, whereas the manifest for this shipment recorded a dose rate of 12 millirem per hour. The licensees corrective actions included providing a corrected shipment manifest to US Ecology and proposed enhancements to the Columbia Generating Station procedures for shipping. This issue was documented in the licensees corrective acti on program as Action Request AR 00369215. The failure to transfer byproduct material to a low-level radwaste disposal facility in accordance with the facilitys license was a performance deficiency. The performance deficiency was more than minor because it was associated with the program and process attribute of the Public Radiation Safety Cornerstone and adversely affected the associated cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. Using NRC Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process, the inspectors determined that the finding had very low safety significance (Green) because it was a low-level burial ground nonconformance; however, it was not Class C waste or greater and the waste did conform to the waste characteristics of 10 CFR 61.56. The finding has a cross-cutting aspect in the area of Human Performance, Resources, because licensee leaders failed to ensure that personnel, equipment, procedures, and other resources were available and adequate to support nuclear safety (H.1).
05000397/FIN-2017002-06Licensee-Identified Violation2017Q2On October 13, 2016, several ARMs unexpectedly alarmed when six filters were simultaneously lifted from the SFP to be placed into a radioactive waste liner . The radiation work permit (RWP) governing performance of the job, RWP 3003788, Revision 00, dated September 7, 2016, had the following , Hold Point , requirements in the event that unexpected radiological conditions occurred during the movement of spent filters: Stop work immediately and notify RP personnel if an unanticipated ARM alarms. If a reading greater than 10 rem/hour contact or 800 millirem/hour at 30 centimeters was detected, but not expected, place the filter back into the SFP . The six filters that had been raised from the SFP had radiation levels as high as 14,000 rem/hour on contact and over 300 rem/hour at almost 30 centimeters. However, the filters were placed in the liner rather than back into the SFP , as specified in the RWP and instructed by RP staff during the evolution. Technical Specification 5.4.1.a requires, in part, that procedures be written, implemented, and established for those areas recommended in Regulatory Guide 1.33, Appendix A, Revision 2, 1978. Section 7(e) of Appendix A recommends written procedures for RWP systems to control access to radioactive materials and limit personnel exposure. Radiation Work Permit 3003788 stated, in part, in the event of unexpected radiological conditions during movement of spent filters, stop work immediately if an unanticipated area radiation monitor alarms, and if a reading greater than 10 rem/hour contact was detected but not expected, place the filter back into the SFP. Contrary to the above, on October 13, 2016 , the licensee f ailed to stop work immediately when several area radiation monitors unexpectedly alarmed and failed to place the filters back into the SFP when readings greater than 10 rem/hour contact were detected but not expected . Subsequently, 16 workers received an addition al 63.5 millirem when the instructions of the RWP and RP staff were not followed. The finding was of very low safety significance (Green) because it did not involve: (1) as-low- as-reasonably achievable (ALARA) planning and controls ; (2) a radiological overexposure; (3) a substantial potential for an exposure; or (4) a compromised ability to assess the dose. This issue was entered into the licensees corrective action program as ARs 356390 and 358265.
05000397/FIN-2017002-04Licensee-Identified Violation2017Q2Title 10 CFR 50.55a(g)4, Inservice Inspection Standards Requirement For Operating Plants , requires , in part, that thro ughout the service life of a boiling water -cooled nuclear power facility, components that are classified as ASME Code Class 1, Class 2, and Class 3 must meet the requirements set forth in Section XI of the ASME Code. The ASME Code, Section XI, Article IWA -2610, requires that all welds and components subject to a surface or volumetric examination be included in the licensees inservice inspection program. This includes identifying each system support that is subject to Section XI requirements. Contrary to the above, prior to March 9, 2017, the licensee did not apply the applicable inservice inspection requirements to all system pressure boundaries within ASME Code Class 1, 2, and 3 boundaries. Specifically, the licensee failed to include the control rod d rive housing welds, as well as portions of the residual heat removal and high pressure core spray systems in their inservice inspection program. The licensee entered this issue into their corrective action program as AR 00343761 and reasonably determined the affected components and system remained operable. The licensee restored compliance by entering the components and systems into the ASME Section XI program. The finding was of very low safety significance (Green) because the finding did not represent an actual loss of safety function of a system or train, and did not result in the loss of a single train for greater than technical specification allowed outage time.
05000397/FIN-2017002-03Inadequate Corrective Actions Causes Failure of HPCS Room Normal Supply Fan2017Q2Green . The inspectors reviewed a self -revealed, non- cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for failure to promptly identify and correct a condition adverse to quality. Specifically, since 2012, the licensee failed t o implement prompt corrective actions to correct an adverse condition related to the use of a contactor coil for a motor starter in the high pressure core spray room normal supply fan. As an immediate corrective action, the licensee replaced the contactor for the high pressure core spray room normal supply fan. The licensee entered this issue into the corrective action program as Action Request 360595. The failure to correct an adverse condition related to the use of a contactor coil for a motor starter in the HPCS room normal supply fan, though the licensee had an opportunity and plan to do so, was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it affected the design control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensees failure to correct the use of a contactor coil for a motor starter in the high pressure core spray room normal supply fan resulted in an inoperable fan, high pressure core spray bus 4160 VAC switchgear, and high pressure core spray pump during the January 25, 2017, event when smoke was observed from the motor control center. The inspectors performed the initial significance determination using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that the finding was of very low safety significance (Green) because: (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding does not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety -significant in accordance with the licensees maintenance rule program for greater than 24 hours. The inspectors determined that this finding did not have a cross -cutting aspect as the decision to not replace the contactor occ urred in 2014 and was not reflective of current performance.
05000397/FIN-2017002-02Failure to Conduct Adequate Surveys of Spent Filters Moved from the Spent Fuel Pool2017Q2Green . The inspectors reviewed a self -revealed, non- cited violation of 10 CFR 20.1501 resulting from the licensee's failure to conduct radiation surveys necessary to establish appropriate controls to support movement of spent filters from the spent fuel pool to a shipping cask. This issue was entered into the licensee's corrective action program as Action Requests 356390 and 358265. The licensees failure to perform surveys necessary to establish appropriate controls to support the movement of filters from the spent fuel pool to a shipping cask was a performance deficiency. The performance deficiency was more than minor because it was associated with the Occupational Radiation Safety Cornerstone attribute of program and process and adversely affected the associated cornerstone objective to ensure adequate protection of worker health and safety from exposure to radiation. Specifically, the inadequate radiation surveys resulted in inadequate controls being implemented causing unplanned and unintended personnel dos e. Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the inspectors determined that the finding was of very low safety significance (Green), because it did not involve: (1) ALARA planning and controls; (2) an overexposure; (3) a substantial potential for overexposure; or (4) an impaired ability to assess dose. The finding had a cross- cutting aspect in the area of human performance, associated with work management, because the organization failed to implement a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. Specifically, the licensees organization and work processes failed to include the identification and management of radiological risk commensurate with the spent fuel pool filter project and the need for strict coordination with different groups or job activities (H.5).
05000397/FIN-2017002-01Mechanism Operated Cell Switch Failure2017Q2Green . The inspectors reviewed a self -revealed finding for the licensees failure to follow plant Procedure SWP -CA P-01, Corrective Action Program, that ensures corrective actions are timely. As a corrective action for failures associated with mechanism operated cell switches for nonsafety 4160 VAC circuit breakers in 2013 and 2015, the licensee assigned modifications to the mechanism operated cell switches but failed to implement t hem in a timely manner. Consequently, on July 20, 2016, circuit breaker E -CB -S/3 mechanism operated cell switches failed to change state resulting in a loss of a main feed pump and an unplanned runback to 70 percent reactor power. As corrective action, the licensee declared the startup transformer inoperable, modified the mechanism operated cell assembly for circuit breaker E -CB -S/3 to remove one switch, and performed post -maintenance testing. The licensee also initiated Action Request 352504 to perform an apparent cause review and address long -term corrective actions. The failure to follow plant Procedure SWP -CAP -01, Corrective Action Program, that ensures corrective actions are timely was a performance deficiency. The performance deficiency was more than minor because it affected the equipment performance attribute of the Initiating Event Cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the loss of major loads on E -SM -3 upset plant stability by causing a loss of feed and reactor runback transient. The inspector performed the initial significance determination using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 1, Initiating Events Screening Questions. The inspectors determined that the finding was of very low safety significance (Green) because the finding did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. Specifically, the licensee remained at power and maintained diverse feed and condensate pumps. This finding had a cross -cutting aspect in the area of human performance, consistent process, in that the licensee failed to use a systematic approach to make decisions including incorporating risk insights. Specifically, circuit breaker E -CB -S/3 is utilized at least monthly 3 for emergency diesel generator surveillance testing and a failure could render the startup transformer inoperable. The mechanism operated cell assembly modification, recommended in 2013 and assigned for action in 2015, was not planned or scheduled as a work order at the time of the failure in 2016 (H.13).
05000397/FIN-2017002-05Licensee-Identified Violation2017Q2Title 10 CFR 50.55a(g)(5 )(i) , ISI Program Update: Applicable ISI Code Editions and Addenda, requires , in part, that the inservice inspection program for a boiling water - cooled nuclear power facility must be revised by the licensee, as necessary, to meet the requirements of paragraph (g)(4) of this section. Paragraph (g)4 (ii ), Applicable ISI Code: Successive 120- Month Intervals, requires, in part, that inservice examination of components and system pressure tests conducted during successive 120- month inspection intervals must comply with the requirements of the latest edition and addenda of the Code incorporated by reference in paragraph (a) of this section, 12 months before the start of the 120- month inspection interval. Contrary to these requirements, the licensee failed to issue the inspection plan for the fourth 10- year inservice inspection interval in a timely manner . Specifically, the licensee failed to issue the inservice inspection plan until January 27, 2016, even though the third 10- year inservice inspection interval had ended on December 13, 2015. A relief request to allow emergent repairs to be completed under the third 10 -year inservice inspection plan was requested by the licensee on December 16, 2015, and was approved by the NRC ; however, no repairs needed to be completed. The finding was of very low safety significance (Green) because the finding did not represent an actual loss of safety function of a system or train and did not result in the loss of a single train for greater than technical specification 31 allowed outage time. This issue was entered into the licensees corrective action program as A R 00341506.
05000397/FIN-2016009-10Licensee-Identified Violation2017Q1The following violation of very low safety (Green) significance was identified by the licensee and is a violation of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as a non-cited violation. Failure to Perform QC Inspections of Radwaste Shipping Liners Prior to Use Technical Specification 5.4.1.a requires, in part, that procedures be written, implemented, and established for those areas recommended in Regulatory Guide 1.33, Appendix A, Revision 2, 1978. Section 7(b) of Regulat ory Guide 1.33, Appendix A, requires procedures for control of radioactive materials to minimize potential releases to the environment associated with solid radwaste. Procedure SWP-RMP-02, Radioactive Waste Process Control Program, Sections 2.11, Quality, and 2.13, Procurement, stated, in part, that: Procurement of items and services s upporting radioactive material transport and disposal shall be performed in accordance with procedure SWP-PUR-01, Procurement of Services, procedure SWP-PUR-04, Material, Equipment, Parts and Supplies Procurement, and procedure SWP-MMP-03, Packaging and Shipping of Material or Equipment, and should be designated as Commercial Grade or Procurement Quality Level 3 as applicable. 51 Columbia Generating Station Programs and Procedures OQAPD, SWP-RMP-02, SWP-PUR-01, and SWP-PUR-04 required the licensees QC staff to inspect PHIC liners when received on-site and prior to first use. Contrary to the above, in April and June of 2015, PHIC liners (later used in shipment Nos. 15-23 and 15-49) arrived on-site and were used without having QC procurement inspections performed prior to use. Consequently, RWCU resin was disposed of at the US Ecology site on April 29 and June 15, 2015, in PHIC liners that were not appropriately inspected. Because this violation was determined to be of very low safety significance and was entered into the licensees corrective action program as ARs 360572 and 338421, this violation is being treated as a licensee- identified non-cited violation consistent with the NRC Enforcement Policy. The failure to perform QC inspection of radwaste shipment liners is a performance deficiency. It adversely affects the Public Radiation Safety Cornerstone objective to ensure adequate protection of the public. Using NRC Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process, the team determined this violation to be of very low safety significance (Green) because: (1) radiation limits were not exceeded, (2) there was no breach of a package during transit, (3) it did not involve a certificate of compliance issue, (4) it was not a low level burial ground nonconformance, and (5) it did not involve a failure to make notifications or provide emergency response information.
05000397/FIN-2016009-02Failure to Conduct Adequate Surveys of a Solid Radwaste Shipment2017Q1Green. The team reviewed three examples of a self-revealed, non-cited violation of 10 CFR 20.1501 associated with the failure to conduct adequate surveys of the solid radwaste contents of a shipment that was packaged and transported for ultimate disposal. As a result of the inadequate surveys, the radwaste in shipment No. 16-40 was packaged in the incorrect type of shipping cask, the radwaste manifest and shipping paperwork contained numerous errors, and the waste was not correctly classified in accordance with 10 CFR Part 61. This issue was entered into the corrective action program as Action Request 357593. The failure to conduct adequate surveys of the solid radwaste contents in a shipment that was packaged and transferred for ultimate disposal was a performance deficiency. The team determined that the performance deficiency was more than minor, and therefore a finding, because it was associated with the program and process aspect of the Public Radiation Safety Cornerstone and adversely affected the cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released in the public domain. Specifically, as a result of the inadequate surveys, the radwaste in shipment No. 16-40 was packaged in the incorrect type of shipping container, the radwaste manifest and shipping paperwork contained numerous errors, and the waste was misclassified in accordance with 10 CFR Part 61. Using NRC Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process, the violation was determined to be of very low safety significance (Green) because it was a finding in the transportation branch in which: (1) radiation limits were not exceeded, (2) there was no breach of the package during transit, (3) there were no Certificate of Compliance issues, and (4) the low-level burial ground nonconformance did not involve a 10 CFR 61.55 waste underclassification. The finding has a cross-cutting aspect in the area of human performance, associated with documentation, because the organization failed to maintain complete, accurate, and up-to-date documentation (H.7).
05000397/FIN-2016009-07Failure to Follow Procedure and Perform a Root Cause Evaluation to Assess the Causes of a Radwaste Shipping Event2017Q1Green. The team identified a finding for the failure to follow the requirements of Procedure SWP-CAP-06, Condition Report Review, when determining the type of 6 cause evaluation required to assess the causes of the higher than expected dose rates on a radwaste container. Specifically, Procedure SWP-CAP-06 required that if an event has high risk and high uncertainty, the level of evaluation required is a root cause evaluation. However, the licensee failed to adequately assess the uncertainty associated with the causes of the event and performed an apparent cause evaluation rather than a root cause evaluation. The licensee entered this finding into the corrective action program as Action Request 360236. The failure to follow the requirements of Procedure SWP-CAP-06 when determining the type of cause evaluation required to assess the higher than expected dose rates on a radwaste container and performing an apparent cause evaluation instead of a root cause evaluation was a performance deficiency. The team determined that the performance deficiency was more than minor, and therefore a finding, because it was associated with the Public Radiation Safety Cornerstone attribute of program and process and adversely affected the cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released in the public domain. Specifically, the failure to adequately assess the causes of the event left the licensee vulnerable to future radwaste processing and transportation errors of significance. Using NRC Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance (Green). The finding has a cros s-cutting aspect in the area of problem identification and resolution, associated with evaluation, because the licensee failed to thoroughly evaluate the issue to ensure resolutions address causes and extent of conditions commensurate with their safety significance (P.2).
05000397/FIN-2017008-02Operators Fail To Follow Procedure Causes RCIC Overspeed Trip2017Q1Green . The inspectors reviewed a self -revealed, non- cited violation of Technical Specificat ion 5.4.1.a, Procedures, for the licensees failure to follow Procedure SOP- RCIC- INJECTION -QC, RCIC RPV In jection Quick Card, Revision 5. During a complicated reactor scram on December 18, 2016, licensed operators failed to open the RCIC turbine trip valve, RCIC -V-1, prior to initiating RCIC. As a result, RCIC tripped on overspeed, required local resetting, and led to licensed operations personnel injecting with the HPCS system , a nonpreferred injection source . As immediate corrective actions, the licensee implemented operations N ight Order 76 that emphasized to operators the correct valve seq uence for initiating RCIC flow. To address additional training aspects of this issue, the licensee updated the RCIC quick card procedure for clarity and added a training module to the next licensed operator requalification cycle on use of RCIC during transients. The licensee entered the unexpected trip of RCIC into the corrective action program as Action Requests 359064 and 359162 . The failure to follow Procedure SOP -RCIC- INJECTION -QC, RCIC RPV In jection Quick Card, Revision 5, was a performance deficiency. This performance deficiency was more than minor, and therefore a finding, because it adversely affected the human performance attribute of the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors performed the initial significance determination using NRC Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At -Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012. The inspectors determined that the finding was of very low safety significance (Green) because: (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding does not represent an actual loss of function of one or more non- technical specification trains of equipment designated as high safety -significant in accordance with the licensees maintenance rule program for greater than 24 hours. This finding had a cross -cutting aspect in the area of human performance, training, in that the licensee failed to provide training and ensure knowledge transfer to maintain a knowledgeable, technically competent workforce and instill nuclear safety values. Specifically, the licensed operator did not understand the sequence of component manipulations for restarting RCIC using the quick card (H.9)
05000397/FIN-2017007-01Failure to Evaluate and Control Nonconforming SSCs2017Q1Green/SL-IV. The team identified a Green, Severity Level IV non-cited violation of 10 CFR Part 50 Appendix B Criteria VII and XV, for the licensees failure to ensure materials intended for installation in safety-related applications conformed to procurement requirements or, if they did not, were adequately controlled and evaluated. The failure to establish a program to evaluate and control nonconforming materials in accordance with the procurement requirements of 10 CFR 21 was a performance deficiency. This performance was more than minor because if left uncorrected it had the potential to become a more significant safety concern. Using Inspection Manual Chapter 0609 Appendix A, dated June 19, 2012, the team determined that this finding was of very low safety significance (Green) because it was a def iciency affecting the design or qualification 3 of a structure, system, or component, and operability was maintained. The finding has a conservative bias cross-cutting aspect in the human performance cross-cutting area because licensee personnel improperly rationalized the adequacy of the nonconforming components to perform their safety-related functions
05000397/FIN-2017008-03Inadequate Corrective Actions Causes Failure of HPCS Restricting Orifice Gasket2017Q1Green . The inspectors reviewed a self -revealed, non- cited violation of 10 CFR Part 50, Appendix B, Criterion XVI , Corrective Action, for failure to promptly identify and correct a condition adverse to quality. Specifically, since 2009, the licensee failed to implement prompt corrective actions to correct an adverse condition related to the use of spiral wound gaskets for restricting orifices in the HPCS system. As an immediate corrective action, the licensee replaced the gasket for restricting orifice RO -5 under Work Order 02105645. The licensee entered this issue into the corrective action program as A ction Request 359066. 4 The failure to implement prompt corrective actions to correct an adverse condition related to the use of spiral wound gaskets for restricting orifices in the HPCS system was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it affected the design control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensees failure to correct the use of incorrect spiral wound gaskets for restricting orifices in the HPCS system resulted in a failed gasket during the December 18, 2016 scram , introduction of foreign material into the suppression pool, and leakage into the HPCS room. The inspectors performed the initial significance determination using NR C Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that the finding was of very low safety significance (Green) because: (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding does not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety -significant in accordance with the licensees maintenance rule program for greater than 24 hour s. The inspectors determined that this finding did not have a cross -cutting aspect as the descision to use incorrect spiral wound gaskets occurred in 2009 and was not reflective of current performance.
05000397/FIN-2016009-05Failure of the QA program to assure compliance with 10 CFR 61.55 and 10 CFR 61.562017Q1Green. The team identified a non-cited violation of 10 CFR Part 20, Appendix G, for the failure to manage a quality assurance program to ensure compliance with 10 CFR 61.55 and 10 CFR 61.56. Additionally, licensee management failed to effectively evaluate the significance of quality assurance audit findings in the area of radwaste processing and radioactive material shipments. The failure to manage a quality assurance program to assure compliance with 10 CFR 61.55 and 10 CFR 61.56 was a performance deficiency. The team determined that the performance deficiency was more than minor, and therefore a finding, because it was associated with the Public Radiation Safety Cornerstone attribute of program and process and adversely affected the cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released in the public domain. Specifically, the failure to manage quality assurance activities as part of the radwaste processing and packaging program resulted in wastes that were not properly classified or did not possess the proper characteristics for burial. Using NRC Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process, the violation was determined to be of very low safety significance (Green) because it was a finding in the transportation branch in which: (1) radiation limits were not exceeded, (2) there was no breach of the package during transit, (3) there were no Certificate of Compliance issues, and (4) the low-level burial ground nonconformance did not involve a 10 CFR 61.55 waste under-classification. The finding has a cross- cutting aspect in the area of human performance, associated with avoiding complacency, because licensee personnel failed to recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes, by not implementing appropriate error reduction tools, such as a proper quality assurance program. Specifically, the licensee has failed to ensure the appropriate level of quality assurance/quality control oversight and verification with respect to risk-significant radwaste processing and radioactive material shipment activities (H.12)
05000397/FIN-2016009-01Shipment of a Type B Quantity of Radioactive Material in a Type A Package2017Q1TBD. The team reviewed a self-revealed finding and apparent violation of 49 CFR 173.427 associated with a shipment of low specific activity (LSA) material consisting of radioactive filters, irradiated components, and dry active waste. The licensee failed to ensure that the radioactive contents in a radwaste liner did not exceed the radiation level requirements for shipping. Specifically, the licensee transported a Type A package containing a Type B quantity of radioactive material as LSA even though it had an external radiation level of 2.1 rem/hr at a distance of 3 meters from the unshielded material, exceeding the 1 rem/hr at 3 meters limit for LSA. This issue was entered into the corrective action program as Action Requests 357593 and 360236. The failure to ensure that the radioactive contents of a radwaste container of low specific activity material did not exceed the requirements for shipping was a performance deficiency. The performance deficiency was more than minor because it was associated with the program and process (Transportation Program) attribute of the Public Radiation Safety Cornerstone and adversely affected the cornerstone objective of ensuring adequate protection of public health and safety from exposure to radioactive material released into the public domain. Specifically, the licensees failure to ensure that the contents of a radwaste container did not exceed the requirements for shipping resulted in radioactive material being transported in Type A packaging rather than the required Type B packaging. The finding was evaluated using NRC Inspection Manual Chapter 0609, Appendix M, Significance Determination Process Using Qualitative Criteria, because Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process, does not specifically address the situation where a Type A package was used to ship quantities of radioactive material requiring a Type B package. In accordance with Appendix M, an initial qualitative bounding evaluation was performed. This was accomplished using the Transportation Branch of 3 the Public Radiation Safety Significance De termination Process and examples from the Enforcement Policy. The finding has a cross-cutting aspect in the area of human performance, associated with conservative bias, because licensee personnel did not use decision-making practices that emphasized prudent choices over those that were simply allowable. Specifically, on several occasions throughout the radwaste processing and packaging evolution for shipment No. 16-40, decisions were made that did not exhibit the appropriate conservative bias (H.14).
05000397/FIN-2016009-03Failure to Label or Provide Written Information for Items Stored in the Spent Fuel Pool2017Q1Green. The team identified a non-cited violation of 10 CFR 20.1904 for the licensees failure to ensure that each container of licensed material in the spent fuel pool bore a label or had documentation providing sufficient information to permit individuals handling the licensed material to minimize exposure. The immediate corrective actions were to generate a condition report and assess the extent of the failure to label or provide sufficient information for all items in the spent fuel pool, reevaluate the latest spent fuel pool annual inventory to identify any missing information, and update applicable procedures. This issue was entered into the corrective action program as Action Requests 357593 and 360148. 4 The licensees failure to ensure that each container of licensed material stored in the spent fuel pool bore a label or had sufficient written information to permit individuals handling the licensed material to minimize exposure was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the programs and process (exposure control) attribute of the Occupational Radiation Safety Cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive ma terial. Specifically, accessing highly radioactive material without sufficient information and unknown radiological conditions could result in unanticipated dose rates and unplanned exposures. Using NRC Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance (Green) because it did not: (1) involve as low as is reasonable achievable (ALARA) planning or work controls, (2) did not involve an overexposure, (3) did not have a substantial potential to be an overexposure, and (4) the ability to assess dose was not compromised. The finding has a cross-cutting aspect in the area of human performance, associated with avoiding complacency, because licensee personnel failed to recognize and plan for the possibility of mistakes and inherent risk, even while expecting a successful outcome, once these items are accessed (H.12).
05000397/FIN-2016009-08Failure to Transfer Byproduct Material to a Disposal Facility in Accordance with the Terms of the Facilitys License2017Q1Green. The team reviewed a self-revealed non-cited violation of 10 CFR 30.41(b)(5) for the failure to transfer byproduct material to an authorized waste disposal facility in accordance with the terms of the facilitys license. Specifically, License Condition No. 22.C of the US Ecology license required that all radwaste shall be packaged in such a manner that waste containers received at the facility do not show an increase in the external radiation levels as recorded on the manifest, within instrument tolerances. On November 9, 2016, the licensee transferred byproduct material to US Ecology for disposal; the disposal facili tys surveys revealed that the dose rate on contact with the waste liner was 90 rem per hour, whereas the manifest recorded a dose rate 11.8 rem per hour. The licensee retrieved the shipment, stored it safely, and entered the condition into the corrective action program as Action Request 357593. The failure to transfer byproduct material to a low-level radwaste disposal facility in accordance with the facilitys license was a performance deficiency. The performance deficiency was more than minor because it was associated with the program and process attribute of the Public Radiation Safety Cornerstone and adversely affected the associated cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reacto r operation. Using NRC Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance (Green) because it was a low-level burial ground nonconformance and a 10 CFR 61.55 waste under-classification; however, it was not Class C waste or greater and the waste did conform to the waste characteristics of 10 CFR 61.56. The finding has a cross-cutting aspect in the area of human performance, associated with conservative bias, because station personnel failed to use decision-making practices that emphasize prudent 7 choices over those that are simply allo wed considering the licensee had multiple opportunities to re-evaluate the shipment and determine the appropriate requirements (H.14).
05000397/FIN-2016009-04Failure to Provide an Accurate Shipping Manifest2017Q1Green. The team identified a non-cited violation of 10 CFR 20.2006(b) for the licensees failure to ship radwaste with an accurate shipping manifest. Specifically, the licensee failed to provide the correct identification number and proper shipping name, radionuclide activity, net waste volume, surface radiation level, and waste classification. The incorrect surface radiation levels resulted in rejection of the package and the licensees immediate suspension from usage of the land disposal site at US Ecology. This issue was entered into the corrective action program as Action Requests 357593 and 359498. The licensees failure to ship radwaste intended for ultimate disposal with an accurate shipping manifest was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the program and process attribute of the Public Radiation Safety Cornerstone and adversely affected the cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive material released in the public domain. Specifically, inaccurate information on a shipping manifest could result in inappropriate handling of radioactive material while in the public domain. Using NRC Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance (Green) because: (1) radiation limits were not exceeded, (2) there was no breach of a package during transit, (3) it did not involve a certificate of compliance issue, (4) it was not a low-level burial ground nonconformance, and (5) it did not involve a failure to make notifications or provide emergency information. The finding has a cross-cutting aspect in the area of human performance, associated with avoiding complacency, because licensee personnel failed to recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes, by not implementing appropriate error reduction tools. Due to the lack of appropriate error prevention tools, inaccurate survey data was provided to the vendor and errors in the waste characterization and shipping manifest were not identified in a timely fashion (H.12).
05000397/FIN-2016009-06Failure to Update the Final Safety Analysis Report with Changes to Radioactive Waste Processing2017Q1SLIV. The team identified a Severity Level IV non-cited violation of 10 CFR 50.71(e) for the failure of the licensee to periodically pr ovide the NRC a Final Safety Analysis Report (FSAR) update with all changes made to the facility or procedures. Specifically, the licensee changed its radwaste management strategy for the spent fuel pool cooling and cleanup system and material being stored in the spent fuel pool. However, the licensee had not changed its process control program or updated the FSAR to reflect the impact on waste streams from processing items stored in the spent fuel pool including activated metals, Tri-Nuke filters, filter socks, and dem ineralizer filter resins. This issue was entered into the corrective action program as Action Requests 359293 and 359296. The failure to update the final safety analysis report to reflect changes in solid radwaste management and the process control program was a performance deficiency. The Reactor Oversight Programs SDP does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which involves the ability of the NRC to perform its regulatory oversight function using traditional enforcement to adequa tely deter non-compliance. Referring to Section 6.1.d. of the Enforcement Policy, the finding is being characterized as a Severity Level IV violation. Traditional enforcement violations are not assessed for cross-cutting aspects.
05000397/FIN-2016009-09Failure to Minimize Void Spaces in a Radioactive Waste Package2017Q1Green. The team reviewed a self-revealed non-cited violation of 10 CFR 61.56(a)(3) for the licensees failure to assure that void spaces within the waste packages were reduced to the extent practicable. Specifically, a ship ment of dry active waste sent to US Ecology in May 2016 arrived at the disposal facility with voids in excess of 15 percent of the total waste volume, contrary to the requirements of US Ecologys Radioactive Material License WN-I019-2, License Condition No. 23. Corrective actions included inspecting the other containers from waste shipment No.16-27 and testing each container for voids. The licensee documented this issue in their corrective action program as Action Request 352217 and performed an apparent cause evaluation. The failure to ship radwaste for disposal without reducing void spaces to the extent practicable was a performance deficiency. The team determined that the performance deficiency was more than minor because it adversely affected the Public Radiation Safety Cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released in the public domain. Specifically, the failure to ensure that void spaces were removed in the radwaste container shipped to US Ecology subjected the disposal facility to the possibility of improper disposal of the waste, in that, the package was susceptible to stability issues. Using NRC Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process, the violation was determined to be of very low safety significance (Green) because: (1) radiation limits were not exceeded, (2) there was no breach of the package during transit, (3) there were no Certificate of Compliance issues, and (4) the low-level burial ground nonconformance did not involve a 10 CFR 61.55 waste under- classification. The finding has a cross-cutting aspect in the area of human performance, associated with teamwork, because individuals and work groups failed to communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained (H.4).
05000397/FIN-2017008-01Operators Fail To Follow Reactor Scram Procedure2017Q1Green . The inspectors reviewed a self -revealed, non- cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to follow Procedure 3.3.1, Reactor Scram, Revision 62. Specifically, the licensee failed to trip the main generator per Procedure PPM 3.3.1, Step 6.2.9, although it was required for a load rejection scram. As a result, during the scram on December 18, 2016, the station vital electrical busses SM -7 and SM -8 transferred to the backup transformer (and to the Division 3 Diesel Generator in the case of bus SM -4), instead of to the preferred electrical source, the startup transformer. As immediate corrective actions, the licensee implemented operations Night Order 75 that reinforced training to trip the main generator on a reactor scram. The licensee entered this issue into the corrective action program as Action Request s 359059 and 361029. The failure to follow Procedure 3.3.1, Reactor Scram, Revision 62, was a performance deficiency. Th is performance deficiency was more than minor, and therefore a finding, because it adversely affected the human performance attribute of the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the performance deficiency result ed in a reduction in the offsite power sources available to supply safety -related busses . The inspectors performed the initial significance determination using NRC Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At -Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012. The inspectors determined that the finding was of very low safety significance (Green) because: (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding does not represent an actual loss of function of one or more non- technical specification trains of equipment designated as high safety -significant in accordance with the licensees maintenance rule program for greater than 24 hours. This finding had a cross -cutting aspect in the area of human performance, training, in that the licensee failed to provide training and ensure knowledge transfer to maintain a 3 knowledgeable, technically competent workforce and instill nuclear safety values. Specifically, the licensed operators did not understand the actions associated with the main generator in the scram procedure (H.9)
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05000397/FIN-2016004-01Failure to Maintain Licensed Operator Examination Integrity2016Q4Severity Level IV. The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 55.49, Integrity of Examinations and Tests, associated with a Green finding, for the failure to ensure the integrity of simulator scenario tests, given as part of the 2015 licensed operator annual operating test, were maintained. The administration practices for the years 2015 and 2016 were reviewed to determine if they were consistent with industry standards used to enforce uniform conditions on the examination process. During the 2015 annual operating test, three licensed operators received two of three simulator scenario tests that had been previously administered to other licensed operators in previous weeks, and two licensed operators received two of two simulator scenario tests that had been previously administered to other licensed operators in previous weeks. Allowing more than 50 percent of an operating test section to be comprised of examination material previously administered on any other test in the same examination cycle is considered an examination integrity compromise. However, an evaluation of the 2015 examination results for the affected population showed that the compromise did not have an actual effect on the equitable and consistent administration of the examination. The licensee entered the finding into the corrective action program as Action Request 358890. The failure of the licensees training staff to maintain the integrity of examinations administered to licensed operations personnel was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it adversely affected the human performance attribute of the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using NRC Inspection Manual Chapter 0609, Significance Determination Process, Attachment 4, Tables 1 and 2 worksheets, and the corresponding Appendix I, Licensed Operator Requalification Significance Determination Process (SDP), the finding was determined to have very low safety significance (Green). Although the 2015 finding resulted in a compromise of the integrity of the annual operating tests, with no compensatory actions immediately taken when the compromise should have been discovered, the equitable and consistent administration of the annual operating test was not actually affected by this compromise. In addition, the failure to meet 10 CFR 55.49 was evaluated through the traditional enforcement process, which resulted in its association with a Severity Level IV (SL-IV) violation consistent with Sections 2.2.4 and 6.4d of the NRC Enforcement Policy. This finding had a cross-cutting aspect in the area of resources associated with ensuring that procedures are adequate to ensure nuclear safety. A review of the procedure used to develop and administer requalification program examinations revealed that it did not specify the industry standards or guidelines that ensure that 50 percent or less of the examination material is repeated on a given examination in comparison to those examination elements used in previous weeks examinations at the individual level (H.1).
05000397/FIN-2016004-02RCIC Trips After Surveillances2016Q4Green. The inspectors reviewed a self-revealed, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to verify the adequacy of design of the reactor core isolation cooling (RCIC) system. Specifically, in 2001, the licensee implemented a design change to the keep-fill pump, RCIC-P-3, that changed its operation from continuous to intermittent, and did not verify the adequacy of the design for all methods of operation, including surveillance testing. Placing the RCIC-P-3 pressure switch downstream of the steam-driven RCIC pumps discharge check valve allows a subsequent hydraulic transient to depressurize RCIC piping below the systems low pressure trip set point. This failure to provide design control measures resulted in RCIC tripping three separate times when RCIC-P-3 was unable to keep up with hydraulic transients. In response to this condition, the licensee changed their operation of the keep-fill pump to running continuously and initiated Action Request 352594 to address long-term issues such as procedure revisions and system design changes. The failure to verify the adequacy of design of the RCIC system was a performance deficiency. Specifically, in 2001, the licensee implemented a design change to the keep-fill pump, RCIC-P-3, that changed its operation from continuous to intermittent and did not verify the adequacy of the design for all methods of operation, including surveillance testing. The performance deficiency was more than minor, and therefore a finding, because it affected the design control attribute of the Mitigating System Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, this modification was inadequate, resulted in RCIC tripping three separate times when RCIC-P-3 was unable to keep up with hydraulic transients, and required compensatory measures to prevent future trips. The inspectors performed the initial significance determination using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that the finding was of very low safety significance (Green) because: (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. The inspectors did not identify a cross-cutting aspect for this issue. Specifically, the design change occurred approximately 15 years ago and does not represent current licensee performance.
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05000397/FIN-2016004-04Licensee-Identified Violation2016Q4Title 10 CFR 55.53, Conditions of licenses, Subpart (f)(2), requires that before the resumption of functions, authorized by a license issued under Part 55, begins, an authorized representative of the facility licensee shall certify that a minimum of 40 hours of shift functions, including a complete tour of the plant, is completed, in part, under the direction of an operator or senior operator as appropriate and in the position to which the individual will be assigned. Contrary to the above, on April 22, 2015, and October 26, 2016, authorized facility representatives certified that two licensed operators had completed the requirements to re-activate their licenses without completing a plant tour under the direction of the appropriate operator. The licensed operators completed plant tours, but an operator with an active license did not accompany them on their tours. Licensee staff identified this issue while performing a pre-NRC inspection focused self-assessment and subsequent extent of condition reviews. The affected licensed operators had their licenses placed on administrative hold until it was determined that they met the requirements of having active licenses. The violation was of very low safety significance (Green) because a prior and similar violations significance bounded this violations significance (Comanche Peak NCV 05000445/2011004-02). The licensee entered this issue into their corrective action program in Action Requests 357779 and 358321.
05000397/FIN-2016004-03Flow Indicating Switch Adjustment2016Q4Green. The inspectors reviewed a self-revealed, non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to implement adequate work instructions for performing maintenance on residual heat removal flow indicating switch RHR-FIS-10B. Specifically, the flow indicating switchs upper drive arm and internal mechanical stops were improperly adjusted which led to increased internal friction. As a result, the associated minimum flow control valve, RHR-FCV-64B, failed to open when securing the system from a surveillance test. As an immediate corrective action, the licensee declared the Division 2 RHR system inoperable, replaced the flow indicating switch, and performed post-maintenance testing. The licensee entered this issue into the corrective action program as Action Request 355027. The failure to implement adequate work instructions for performing maintenance on residual heat removal flow indicating switch RHR-FIS-10B was a performance deficiency. Specifically, the flow indicating switchs upper drive arm and internal mechanical stops were improperly adjusted which led to increased internal friction. As a result, the associated minimum flow control valve, RHR-FCV-64B, failed to open when securing the system from a surveillance test. The performance deficiency was more than minor, and therefore a finding, because it affected the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, RHR-FIS-10B failed to change state, the Division 2 RHR system was declared inoperable, and the licensee replaced the flow indicating switch. The inspector performed the initial significance determination using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that the finding was of very low safety significance (Green) because: (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. This finding had a cross-cutting aspect in the area of human performance, avoid complacency, in that the licensee failed to recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Specifically, the station technicians did not recognize their improper adjustment of the flow indicating switch could lead to failure although training was given on adjustments (H.12).
05000397/FIN-2016002-02Licensee-Identified Violation2016Q2Title 10 of the Code of Federal Regulations, Part 50.54(q)(2), requires, in part, that a power reactor licensee follow and maintain the effectiveness of an approved emergency plan which meets the requirements of Appendix E to Part 50, and the planning standards of 10 CFR 50.47(b). The Columbia Emergency Plan, Revision 62, Section 8.7.3, requires a periodic drill involving the response to a simulated injury with contamination. The Columbia Emergency Plan, Revision 62, Table 8-1, defines the drill periodicity as annual. Contrary to the above, between January 1, 2015, and December 31, 2015, Columbia Generating Station failed to follow and maintain the effectiveness of an approved emergency plan which meets the requirements of Appendix E to Part 50, and the planning standards of 10 CFR 50.47(b). Specifically, Columbia Generating Station failed to perform a drill involving the response to a contaminated and injured persons during the annual period, 2015, as required by the Columbia Generating Station Emergency Plan, Revision 62. The violation was more than minor because the performance deficiency adversely affected the Emergency Preparedness cornerstone objective and was associated with the ERO performance cornerstone attribute. The violation was assessed using MC 0609, Appendix B, Emergency Preparedness Significance Determination Process, dated September 23, 2014, and was determined to be of very low safety significance (Green), because it was a failure to comply with NRC requirements, was not a risk-significant planning standard issue, and was not a degraded or lost planning standard function. The violation was entered into the licensees corrective action program as Action Requests 00342463 and 00347490.
05000397/FIN-2016002-01Loss of RCC Cooling Requiring a Reactor Scram2016Q2The inspectors reviewed a self-revealed, non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to follow procedure OI-41, Operations Work Control Expectations, Revision 59. Specifically, the licensee incorrectly marked steps of procedure OSP-FPC/IST-Q701, Fuel Pool Cooling System Operability Surveillance, Revision 34, as not applicable and therefore did not provide mechanical isolation between the non-safety reactor closed loop cooling system and the safety-related standby service water system. As a result, on March 28, 2016, the reactor closed loop cooling system was momentarily depressurized into the service water system and required a manual reactor scram due to a loss of reactor closed loop cooling for non-safety systems. The licensee entered this issue into their corrective action program as Action Request 346945. The failure to follow procedure OI-41, Operations Work Control Expectations, Revision 59, was a performance deficiency. This performance deficiency was more than minor, and therefore a finding, because it adversely affected the configuration control attribute of the Initiating Events Cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 1, Initiating Events Screening Questions, dated June 19, 2012, the inspectors determined the finding was of very low safety significance (Green) because the finding did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. The finding had a cross-cutting aspect in the area of human performance associated with avoiding complacency because the licensee failed to recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes including implementing appropriate error reduction tools. Specifically, licensed operators failed to recognize the possible latent issues and inherent risk of marking large portions of a procedure as not applicable. (H.12)
05000397/FIN-2016007-01Programmatic Concern Pertaining to Columbia Generating Stations Procedures2016Q2The team identified a Green, non-cited violation of Technical Specification 5.4, Procedures, Section 5.4.1, which states, in part, Written procedures shall be established, implemented, and maintained covering the following activities: a. The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978; Regulatory Guide 1.33, Revision 2, Appendix A, Section 1, Administrative Procedures, Subsection d, specifies Procedure Adherence and Temporary Change Method. This requirement includes plant Procedure SWP-PRO-01, Procedure and Work Instruction Use and Adherence, Revision 27; Procedure SWP-PRO-02, Preparation, Review, Approval and Distribution of Procedures, Revision 42; and Procedure SWP-PRO-03, Writers Manual, Revision 21, which identify the requirements governing procedural requirements utilized at Columbia Generating Station. Specifically, from June 6 through June 23, 2016, multiple examples of procedural compliance were identified with the station procedures. These examples include failure to follow procedures, inadequate procedures, not correctly translating design requirements into procedures, validation of procedures, and the distribution of procedures. In response to this issue, the licensee reviewed each individual concern and confirmed that there were no operability concerns. The licensee has also placed each identified concern into their corrective action program and will address each issue. This finding was entered into the licensees corrective action program as Action Request (AR) 00351364. The team determined that the licensees failure to follow guidance procedures for implementation, adherence, accuracy, verification, and distribution of station procedures, was a performance deficiency. This finding was more than minor because it was associated with the procedures attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failing to have accurate procedures, and to comply with these procedures, was a significant programmatic deficiency that could adversely affect the reliability and capability of systems used to prevent undesirable consequences. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of nontechnical specification equipment; and did not screen as potentially risk-significant due to seismic, flooding, or severe weather. The team determined that this finding had a cross-cutting aspect in the area of human performance, resources, where the licensee will ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. Specifically, the licensee had not ensured that site procedures were adequate to support plant activities (H.1).
05000397/FIN-2016405-02Licensee-Identified Violation2016Q1
05000397/FIN-2016001-01Licensee-Identified Violation2016Q1Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, prior to November 17, 2015, the licensee failed to establish measures to assure that conditions adverse to quality are promptly identified and corrected. Specifically, in October 2012, the licensee identified in AR 271801 that the maintenance procedure for Square D QMB electrical disconnects, specified in procedure PPM 10.25.53, Inspection of Lighting Panels and Power Panels, Revision 10, did not include steps to clean and burnish contacts that are susceptible to corrosion that may yield a high-resistance connection. However, the licensee failed to identify that several installed QMB disconnects may be vulnerable to failure since the previous maintenance performed did not include the steps to clean and burnish the contacts. Consequently, on November 17, 2015, the 125 VDC circuit (E-DP-S1/2D circuit 6) associated with under voltage trips of the division 2 vital bus failed a monthly surveillance test due to degraded voltage from high-resistance connections on corroded contacts. The licensee implemented corrective action by declaring affected components inoperable per technical specifications, identified high-resistance contacts as the cause, burnished the contacts to restore the circuit, and re-performed the surveillance to establish operability. The licensee also performed relay testing to demonstrate 125 VDC circuit availability at the observed, degraded voltages. The inspectors assessed the finding in accordance with Inspection Manual Chapter (IMC) 0609, Appendix A, The Significance Determination Process for Findings at Power, issued June 19, 2012. Using Exhibit 2 of IMC 0609, the inspectors determined the finding was of very low safety significance (Green) because the finding did not represent a loss of safety function, did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time, and did not represent an actual loss of function of one or more non-technical specification equipment for greater than 24 hours. This violation was entered into the licensees corrective action program as AR 340134.
05000397/FIN-2016405-01Security2016Q1
05000397/FIN-2015004-01Incorrect Electrical Component Operated During Maintenance2015Q4The inspectors reviewed a self-revealing non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to implement Work Order 02048855 during maintenance on a safety-related power panel. Specifically, the licensee operated an incorrect electrical disconnect, E-DISC-7AA-6A. Further, upon realization of the error, maintenance personnel re-energized the E-DISC-7AA-6A circuit without understanding the effects of that action. As a result of this incorrect component operation, the division 1 emergency diesel generator was rendered inoperable. As an immediate corrective action, the licensee stopped all associated maintenance and restored the division 1 emergency diesel generator to operable status by performing the standby alignment procedure. The licensee entered this issue into their corrective action program as Action Request 337018. The failure to implement Work Order 02048855 during maintenance on a safety-related power panel was a performance deficiency. This performance deficiency was more than minor, and therefore a finding, because it adversely affected the configuration control attribute of the Mitigating Systems Cornerstone objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the inspectors determined the finding was of very low safety significance (Green) because the finding did not represent a loss of safety function, did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time, and did not represent an actual loss of function of one or more non-technical specification equipment for greater than 24 hours. The inspectors determined the finding had a cross-cutting aspect in the area of human performance associated with the avoid complacency component because the licensee failed to recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes including implementing appropriate error reduction tools. Specifically, the maintenance staff failed to follow the sites error prevention tool process and operated the incorrect component.
05000397/FIN-2015008-02Inadequate Alternative Shutdown Procedure2015Q4The team identified a non-cited violation of Technical Specification 5.4, Procedures, for the failure to provide adequate procedures to implement the fire protection program. Specifically, the alternative shutdown procedure failed to assure operator actions for post-fire safe shutdown would be performed within the required times following a control room evacuation due to fire. The licensee entered this issue into their corrective action program as Action Request AR-00335854 and issued Night Order Number 1668 providing direction to the operators as a compensatory measure until they completed additional corrective actions. The failure to provide an adequate procedure to assure operators performed post-fire safe shutdown actions within the required time following a control room evacuation due to fire was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external events (fire) attribute of the Mitigating Systems cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The team evaluated this finding using Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, dated September 20, 2013. Since operators would take more than the 10 minutes specified in their procedure to initiate reactor depressurization, the team could not determine that the operators had maintained the ability to reach and maintain safe shutdown conditions. The dominant core damage sequences involved (1) a fire in the control room that required a control room evacuation and (2) the failure of operators to initiate emergency depressurization. Therefore, a Region IV senior reactor analyst performed a bounding detailed risk evaluation. The analyst noted that additional time was available in a probabilistic risk assessment calculation. The additional time available in a probabilistic risk assessment calculation helped to minimize the risk. Based on this information, the finding screened to Green because the licensee could achieve safe shutdown. The finding did not have a crosscutting aspect since the performance deficiency was more than three years old and not indicative of current performance.
05000397/FIN-2015008-03Licensee-Identified Violation2015Q4Fire Protection License Condition 2.C.14, Fire Protection Program (Generic Letter 86-10), states that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in Section 9.5.1 and Appendix F of the final safety analysis report. Final safety analysis report, Table F.3-2, Comparison with the Specific Commitments to 10 CFR Part 50, Appendix R, Section III.G.2, Fire Protection of Safe Shutdown Capability, states, in part, that cables or equipment, including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are free of fire damage. Contrary to this, the licensee failed to ensure that cables or equipment that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground of redundant trains of a systems necessary to achieve and maintain hot shutdown conditions are free of fire damage. The licensee documented in Action Request AR 00332688 that during a self-assessment for fire protection and post-fire safe shutdown programs, a multiple spurious operations scenario related to flow diversion from the suppression pool to the condensate storage tank was missed. It was identified that fire-induced circuit damage to cables for HPCS-V-10, HPCS-V-11, HPCS-V-15, HPCS-P-1, and HPCS-P-3 would cause a condition that could challenge operations achieving and maintaining safe shutdown conditions. The team screened the violation using Inspection Manual Chapter 0609, Appendix F, requiring a Phase 2 screening as described in Attachment 1. The team concluded that the violation screens to very low safety significance because the ignition sources screen out during the Phase 2 significance determination process.
05000397/FIN-2015008-01Failure to Ensure Adequate Acceptance Criteria in Fire Main Surveillance Testing2015Q4The team identified a non-cited violation of License Condition 2.C.14, Fire Protection Program (Generic Letter 86-10), for the failure to establish procedural guidance for validating the underground fire main condition to ensure the required fire suppression system demands were met. Specifically, the licensee failed to provide acceptance criteria in Plant Procedure Manual 15.4.2, Fire Main Hydraulic Data Acquisition, to validate that the fire water supply at the base of the largest demanding fire suppression system was adequate given the current condition of the fire main. From review of design information, the team verified the licensee met their fire protection system design flow and pressure requirements, determined that other pumps would be available, and determined this finding did not affect the ability to achieve safe shutdown. The licensee entered this deficiency in their corrective action program as Action Request AR-00335821. The failure to provide adequate acceptance criteria to validate the condition of the water supply was a performance deficiency. Specifically, the licensee failed to provide adequate acceptance in the Plant Procedure Manual 15.4.2 for Surveillance Requirement 1.10.1.14 to ensure that the current fire water supply can meet the largest demanding fire suppression system. The performance deficiency was more than minor because it was associated with the protection of external events attribute (fire) of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The team evaluated the finding using Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, because it affected the firewater supply category. Using Appendix F, Attachment 1, Fire Protection Significance Determination Process Phase 1 Worksheet, Task 1.4.7, Fire Water Supply, the team assigned a very low safety significance (Green) to the finding because of the availability of at least 50 percent of the required firewater capacity. The team confirmed this after verifying the water supply exceeded the minimum in the water supply calculations, the availability of additional fire pumps beyond that required for the minimum water supply and the condition did not affect the ability to achieve safe shutdown. The finding did not have a cross-cutting aspect since the performance deficiency was more than three years old and not indicative of current performance.
05000397/FIN-2015004-02Licensee-Identified Violation2015Q4Technical Specification 5.4.1.a, Procedures, requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978. Paragraph 9.a of Regulatory Guide 1.33, Appendix A, requires, in part, written procedures for performing maintenance that can affect the performance of safety-related equipment. The licensee established Procedures ISP-MS-Q901, RPS, Reactor Water Level Low, Level 3 Div 1 CFT/CC, Revision 10, and PPM 10.24.34, PM Calibration Test Barton Differential Indicating Switch, Revision 13, to meet the Regulatory Guide 1.33 requirements when performing maintenance on safety-related Barton main steam level indicating switches. Contrary to the above, prior to June 25, 2015, the licensee failed to maintain written procedures for performing maintenance that can affect the performance of safety-related equipment. Specifically, the licensee failed to include instructions in Procedures ISP-MS-Q901 or PPM 10.24.34 for setting the mechanical stop inside Barton main steam level indicating switches. Subsequently, the mechanical indicator in the switches for MS-LIS-24A and MS-LIS-24C became mechanically bound on the rubber stop within the switch when the level was raised off-scale high during the refueling outage. The licensee implemented corrective action by inserting a half scram signal to comply with technical specifications, calibrating the affected switches including steps to set the mechanical stop, and initiating a condition report. The finding represented a loss of safety system function for reactor water level low (level 3) scram signals and for shutdown cooling isolation logic. Because the finding affected mitigating equipment during at-power and shutdown operations, the inspectors assessed the finding in both the Inspection Manual Chapter (MC) 0609, Appendix A, Significance Determination Process for At-Power Findings, and MC 0609, Appendix G, Shutdown Operations Significance Determination Process. Using Exhibit 2 of MC 0609, Appendix A, and Exhibit 3 of MC 0609, Appendix G, inspectors determined that the finding required a detailed risk evaluation for the at-power portion of the finding and a Phase 2 evaluation for the shutdown portion of the finding because the finding represented a loss of safety-system function. A Region IV senior reactor analyst determined the issue was of very low safety significance (Green) and represented a total change to the core damage frequency of 4.4E-7/year. The dominant sequences were anticipated transients without scram and shutdown loss of inventory. For the at-power exposure, risk was mitigated by the use of the standby liquid control system and recirculation pump trips for the anticipated transients without scram. For the shutdown exposure, risk was mitigated by automatic injection by an emergency core cooling system pump for the losses of inventory. This issue was entered into the licensees corrective action program as AR 332078.
05000397/FIN-2015003-03Failure to Provide Design Control Measures for Control Room Emergency Chillers2015Q3The inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to verify the adequacy of the design of the control room HVAC system. Specifically, the licensee failed to demonstrate the ability of control room HVAC design to maintain the temperatures in the main control room below habitability and environmental qualification limits, for the duration of all accident scenarios. The licensee initiated Action Request 332565 to document the concern, issued night order 1662 to communicate the issue, aligned both control room air handling units to their respective chillers, created a quick card procedure to perform the chiller reset actions, and validated the quick card actions could be accomplished within 10 minutes. Additionally, the licensee determined that operators could restore the chillers during accident conditions within 90 minutes to prevent temperatures from exceeding equipment operability limits. The performance deficiency was more than minor because it adversely affected the design control attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined the finding was of very low safety significance because (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. This finding had a cross-cutting aspec in the area of problem identification and resolution, evaluation, in that the licensee did not thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, the licensee did not thoroughly evaluate the extent of condition from NRC-identified NCV 05000397/2013002-04, Failure to Obtain NRC Approval for Changes to Control Room HVAC Requirements, fo the effect of this change on other station calculations (P.2).
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